OSHA has scheduled three informal public hearings in March and April to consider comments and testimony on the proposed rule to align the agency’s Hazard Communication Standard (HCS) with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). For locations and more information about the meetings, go to www.osha.gov. But know this: The GHS provides a single, harmonized system to classify chemicals, labels and safety data sheets with the primary benefit of increasing the quality and consistency of information provided to workers, employers and chemical users.

OSHA’s proposal is receiving pretty enthusiastic support from at least two safety associations, the American Industrial Hygiene Association and the American Society of Safety Engineers, who seek to ensure that the hazards of all chemicals are evaluated and communicated to those who need to know.

“AIHA members rely on federal and state rules and regulations to improve the health and safety of the workplace and protect employees from hazards, including hazards associated with chemical manufacturing, labeling, and handling,” said AIHA President Cathy Cole, CIH, CSP.

For this reason, AIHA is supporting the efforts of OSHA to work with the international community, as well as for the development of criteria for combustible dust as part of the GHS regulations and encouraged the proposed development of a database of classifications.

AIHA also suggested enhancements to certain sections, such as an inclusion of a nonmandatory appendix to the HCS that contains reference to the Threshold Limit Values (TLVs) and other occupational exposure limits like Workplace Environmental Exposure Levels (WEELs).

ASSE notes that modifying OSHA’s existing Hazard Communication Standard (HCS) is a step forward in harmonizing chemical hazard communications worldwide and will help U.S. employers compete in the international marketplace as well as increasing work safety.

“Modifying OSHA’s existing HCS… is necessary to help this nation’s workers deal with the increasingly difficult challenge of understanding the hazards and precautions needed to handle and use chemicals safely in the world marketplace,” said Christopher Patton, CSP, president of ASSE. “At the same time, harmonizing hazard communications with GHS will help U.S. employers compete in that marketplace by lessening the burden of conforming with different regulations and by ensuring their products will meet hazard communication requirements in other nations.”

Though Patton applauded OSHA for its leadership, he did express ASSE’s disappointment that control banding has been largely ignored in the development of the revised standard.

In June 2005, ASSE published “Control Banding and the Future of the HazCom Standard,” a position paper that urged OSHA and the Mine Safety and Health Administration (MSHA) to consider the use of Control Banding (CB) models in a revised HCS. ASSE believes OSHA should update the HCS to incorporate elements of CB.

CB is a technique used to guide the assessment and management of workplace risks. It is a generic technique that determines a control measure (for example dilution ventilation, engineering controls, containment, etc.) based on a range or “band” of hazards (such as skin/eye irritant, very toxic, carcinogenic, etc) and exposures (small, medium, large exposure), according to the National Institute of Occupational Safety and Health (NIOSH).

“When this nation is so close to harmonization with GHS, it would be unfortunately short-sighted not to take the extra step of incorporating control banding since many of the necessary tools to do so are already included in this rulemaking,” Patton said. “Daily, our members experience the reality that we live in a world of commerce that is becoming more and more interconnected. They need the tools to help both the employees and employers with whom they work. To that end, all employers should be required to adopt a revised HCS.”